CONTINUOUS MONITORING SYSTEM PERFORMANCE REPORTING - DEFINING CMS DOWNTIME
Hazardous waste combustion facilities are already familiar with most of the recordkeeping requirements included in 40 CFR 63, Subpart EEE due to previous compliance with the Boiler and Industrial Furnace (BIF) rule. The NESHAP, however, requires semi-annual continuous monitoring system (CMS) performance reporting that was not previously required under BIF. These provisions specify numerous items that must be reported for each required continuous monitor in order to demonstrate compliance with Subpart EEE. Tracking and categorizing each CMS downtime event is substantially more difficult than simply tracking exceedances of an operating parameter.